Page 21 - BusinessWest July 24, 2023

ing company,’ which is an entity that employs more than 20 full-time employees in the U.S., has an operating presence at a physical office within the U.S., and has filed a federal income-tax or information return in the U.S. for the previous year with more than $5 million in gross receipts or sales.
What Is Being Reported?
• Entity information. This includes full legal name, ‘doing business as’ name, principal office address, jurisdiction of formation, and IRS employer identification number.
• Beneficial owner information. A ‘beneficial owner’ is anyone who owns more than 25% of the entity and anyone who exercises ‘substan- tial control’ over the entity’ such as directors, LLC managers, and cer- tain trustees. The entity will need to provide, for each beneficial owner, their full legal name, date of birth, current residential address, govern- mental identification information from a passport or driver’s license, and a copy of that identification document.
• Company applicant information. For new entities formed after Jan. 1, 2024, the entity will need to provide essentially the same infor- mation on the appropriate company applicant individuals as they pro- vide for the beneficial owners.
When Are the Reports Due?
There are two timelines, one for existing businesses formed prior to Jan. 1, 2024, and one for those new businesses formed after the start of the new year. The existing businesses have until Jan. 1, 2025 to submit their initial reports. New businesses will have to file their initial reports to FinCEN within 30 calendar days of their initial formation. Addition- ally, whenever there is a change in beneficial ownership or a change to the information of a beneficial owner, the entity will have 30 days from that change to file an updated report.
Corporate
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